To keep you informed of recent activities, below are several of the most significant federal events that have influenced the Consumer Financial Services industry over the past week.

Federal Activities

State Activities


Federal Activities:

On June 12, the Commodity Futures Trading Commission’s (CFTC) Division of Market Oversight issued a no-action letter permitting designated contract markets (DCMs) to convert existing perpetual-style digital commodity futures contracts into true digital commodity perpetual futures by removing expiration dates, subject to certain customer protection and procedural conditions, including soliciting feedback from market participants with open positions, providing advance notice and an opportunity to exit positions, offering appropriate risk disclosures, and ensuring no other material contract terms are modified. DCMs are also required to file amendments under CFTC Regulations 40.5 or 40.6 and certify compliance. The no-action relief expires on June 30, 2026. For more information, click here.

On June 12, the CFTC issued a Notice of Proposed Rulemaking (RIN 3038-AF65) proposing amendments to 17 CFR Part 40 governing event contract derivatives, commonly known as “prediction markets.” The proposed rule would further specify the types of event contracts that may be deemed contrary to the public interest and therefore prohibited from being listed for trading or accepted for clearing on CFTC-registered entities under the Commodity Exchange Act (CEA), setting out specific factors the Commission would apply in making such determinations while conforming the determination process to the CEA. Additional proposed amendments include enhancements to procedural clarity and organization, a new definition of the term “gaming,” and a rule addressing when event contracts “involve” an underlying activity. Public comments must be submitted in writing by July 27, 2026. For more information, click here.

On June 12, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued updated guidance clarifying how financial institutions may share information about suspected fraud, money laundering, terrorist financing, and other unlawful activities under § 314(b) of the USA PATRIOT Act. The guidance specifies that financial institutions may share such information with any other institution eligible to participate in the § 314(b) program and provides concrete examples of shareable information, including video surveillance footage, cyber-related data such as IP addresses, and fraud indicators like newly added payees followed by large transfers, multiple accounts with matching or similar identifying information, and login activity from geographically distant locations. The updated guidance supports the Trump administration’s whole-of-government anti-fraud initiative, led by the White House Task Force to Eliminate Fraud under Vice President JD Vance, and reflects Treasury’s broader effort (in partnership with federal banking agencies) to modernize the U.S. anti-money laundering and countering the financing of terrorism (AML/CFT) regime to be more risk-based and outcomes-focused, enabling financial institutions to direct greater resources toward higher-risk customers and activities. For more information, click here.

On June 12, Treasury Secretary Scott Bessent delivered remarks to Texas bankers in Houston, emphasizing the critical role community banks play in safeguarding the U.S. financial system against fraud, money laundering, and illicit activity tied to criminal organizations and cartels. Bessent highlighted that financial institutions reported more than $2.5 billion in suspicious activity associated with payroll tax fraud schemes in 2025 alone, and noted that Treasury and FinCEN recently issued guidance identifying red flags related to unlawful employment, labor brokers, shell companies, payroll tax evasion, and identity theft to help banks detect and report such schemes. He announced that FinCEN was simultaneously rolling out updated guidance enabling financial institutions to share fraud-related information in real time and in closer coordination with one another, in support of the Trump administration’s broader anti-fraud initiative led by the White House Task Force to Eliminate Fraud under Vice President JD Vance. Bessent closed by urging community banks to continue building partnerships with Treasury, FinCEN, and law enforcement (filing suspicious activity reports, investing in compliance and training, and sharing information) framing their work not merely as financial services but as essential national security work. For more information, click here.

On June 11, U.S. Senators Elizabeth Warren (D-MA) and Richard Blumenthal (D-CT) introduced the AI Bubble Transparency Act, legislation that would direct the Office of Financial Research to collect data from banks, insurers, private credit funds, and other financial institutions on their exposure to debt and equity instruments connected to AI companies, including chip makers, data centers, cloud providers, model developers, and data infrastructure operators. The bill would also require the Financial Stability Oversight Council (FSOC) to issue a public report on the findings of that data collection, evaluate the channels through which an AI-driven financial shock could threaten the broader financial system, and make recommendations to financial regulatory agencies and Congress to mitigate those risks. The legislation was introduced ahead of the Senate Banking Committee’s June 11 hearing titled “AI and the American Dream: Promoting Innovation, Affordability, and American Dominance,” which featured testimony from Mike Flynn of the Information Technology Industry Council, David Feith of the Hudson Institute, Will Rinehart of the American Enterprise Institute, and Dr. Sarah Myers West of AI Now, and reflects Senator Warren’s broader efforts to press the FSOC and Treasury Department to formally investigate the financial stability risks posed by the rapid growth of AI-related debt financing, which supporters of the bill have characterized as increasingly reliant on opaque debt markets and complex financial arrangements. For more information, click here and here.

On June 11, Senate Banking Committee Chairman Tim Scott (R-SC) appeared on television to discuss the committee’s digital asset legislation priorities and preview the day’s hearing on artificial intelligence in financial services. On digital assets, Chairman Scott emphasized that the committee’s work, including the Clarity Act, is focused on establishing clear rules of the road to protect consumers, lower transaction costs, and strengthen U.S. dollar dominance, noting that stablecoins are already reinforcing the dollar’s status as the world’s reserve currency by requiring dollar or U.S. Treasury backing for every token issued. On artificial intelligence, Chairman Scott stressed that the committee’s primary objectives are protecting consumers and American workers, supporting domestic innovation, and ensuring that AI technology is developed by American companies with American values rather than ceding leadership to China, describing the hearing as the first in a series of Banking Committee sessions aimed at building a thorough understanding of AI’s implications for financial services before developing a regulatory framework. For more information, click here.

On June 11, the CFTC published a Notice of Proposed Rulemaking to amend its whistleblower rules, proposing to incorporate a 30% presumption for whistleblower awards of $5 million or less, subject to commission discretion and its analysis of relevant regulatory factors. The proposal is modeled on the Securities and Exchange Commission’s (SEC) Rule 21F-6(c), continuing the ongoing harmonization efforts between the two agencies, and is intended to improve the efficiency, transparency, and predictability of whistleblower award claims processing. The comment period will remain open for 30 days following publication of the proposed rule in the Federal Register. For more information, click here.

On June 11, the SEC proposed amendments to rescind Rules 611 and 610(e) of Regulation NMS, marking a significant shift in U.S. equity market structure after more than two decades under those rules. Rule 611, known as the trade-through prohibition, and Rule 610(e), which restricts locking and crossing quotations in national market system stocks, would both be eliminated, along with related defined terms in Rule 600 and conforming changes to other provisions. SEC Chairman Paul S. Atkins framed the proposal as an effort to simplify market structure, reduce costs for market participants, and allow competition and innovation to drive the continued evolution of equity markets, acknowledging that Rule 611’s unintended consequences have hindered rather than enhanced long-term market growth. The public comment period will remain open for 60 days following publication of the proposing release in the Federal Register. For more information, click here.

On June 11, the Office of the Comptroller of the Currency (OCC) released a notice and request for comment on proposed reporting forms and instructions for permitted payment stablecoin issuers and foreign payment stablecoin issuers subject to OCC jurisdiction. In March 2026, the OCC issued a proposed rule implementing the GENIUS Act’s requirements for entities under its jurisdiction. The June 11 notice builds on that rulemaking by proposing specific weekly and quarterly reporting forms that permitted payment stablecoin issuers and foreign payment stablecoin issuers would be required to complete. For more information, click here.

On June 11, the OCC, together with eight other federal agencies, issued a joint final rule implementing the Financial Data Transparency Act of 2022 (FDTA), establishing joint data standards for certain collections of information reported by regulated financial entities and data collected on behalf of the FSOC. The joint data standards adopt several common identifiers, including ISO 17442 for legal entity identification, ISO 4914 for swaps and security-based swaps product identification, ISO 8601 for dates, ISO 4217 for currency codes, U.S. Postal Service abbreviations for U.S. states, and ISO 10962 for the classification of financial instruments that are not swaps or security-based swaps, along with data transmission and schema standards designed to ensure that reported data is fully searchable, machine-readable, and consistently identified in machine-readable metadata. Notably, the final rule departs from the August 2024 proposed rule in several respects, including by declining to adopt the Financial Instrument Global Identifier as a standard for identifying financial instruments. The joint data standards do not take effect with respect to any specific collection of information until each agency separately adopts those standards through its own rulemaking or other action, and the rule does not affect community banks. For more information, click here.

On June 11, the Bank for International Settlements published a working paper entitled “The Anatomy of Stablecoin Transactions,” examining how stablecoins are actually used within blockchain-based financial systems by analyzing over 593 million event logs from 141 million Ethereum transactions involving three major U.S. dollar-denominated stablecoins executed in 2025. The paper’s central finding is that stablecoin activity is far more complex than simple peer-to-peer payments: roughly one third of all stablecoin transactions involve multiple steps and computational complexity well beyond a basic payment, and because those complex transactions each generate multiple transfer events, nearly 60% of all transfer events occur within complex transactions rather than as standalone payments. The authors also find that the three stablecoins studied are not used interchangeably, with each exhibiting distinct patterns in transaction complexity, urgency, timing, and integration with financial protocols — reflecting differences in their institutional design and economic function. The paper argues that analyses treating individual stablecoin transfers as standalone payments risk materially misclassifying the nature and scale of on-chain stablecoin activity, with significant implications for empirical research, market monitoring, regulatory frameworks, and the design of policies aimed at enhancing the safety and efficiency of blockchain-based financial systems. For more information, click here.

On June 11, The New York Times reported that the Trump administration, in a 1,121-page final rule governing how the Affordable Care Act (ACA) marketplace will operate next year, has suggested that health insurers consider offering loans to customers who cannot afford high out-of-pocket medical costs — a proposal that critics say would deepen the financial burden on the more than one-third of American households already carrying medical debt. The idea emerged against a backdrop of sharply rising ACA premiums, which now average $178 per month compared to $113 in 2025, following Congress’s decision to end enhanced federal subsidies, with average annual deductibles now approaching $4,000 per person and Bronze plan out-of-pocket maximums exceeding $10,000 for individuals. The administration framed the lending concept as a way to help consumers who chose low-premium, high-deductible plans and then faced unexpected catastrophic medical bills, and also proposed expanding eligibility for bare-bones catastrophic plans (with family deductibles potentially exceeding $31,000 by 2028) as a tool to lower monthly premiums. Health policy experts, researchers, and several cities and health care organizations have pushed back sharply, with ongoing litigation arguing the new rules will cause at least three million Americans to lose ACA exchange coverage in 2026 alone, and medical researchers warning that high-deductible plans already cause patients to delay or forgo care, with one trauma surgeon calling the loan idea “the opposite of a solution” since it merely restructures who holds the debt rather than addressing the underlying cost of care. For more information, click here.

On June 10, President Trump sent to the Senate his nomination of Brian Johnson to serve as director of the Consumer Financial Protection Bureau (CFPB) for a five-year term. The CFPB has been without a confirmed, full-time director since former Director Rohit Chopra was fired on February 1, 2025. Johnson currently serves as an executive at Capital One. He previously served as deputy director of the CFPB during Trump’s first term and has an extensive background on Capitol Hill, having held roles including policy director and chief financial institutions counsel on the House Financial Services Committee. Johnson’s nomination now heads to the Senate for confirmation. For more information, click here.

On June 10, the Financial Stability Board (FSB) published a consultation report on Sound Practices for Responsible Adoption of Artificial Intelligence, identifying 12 sound practices designed to help financial institutions responsibly navigate AI adoption in a rapidly evolving technological landscape. The sound practices are organized across three areas: organization-wide AI governance; management and mitigation of AI risks through the different stages of AI development and deployment; and management of AI-related cyber, information and communication technology, and third-party risks. The FSB strongly encourages boards and senior management of financial institutions to reference the practices as they consider business strategy, technology adoption, and risk management, while noting that the sound practices are not intended to establish an international standard, impose a prescriptive approach, or address risks specific to frontier AI models, though some practices may help institutions respond to those risks as well. The FSB is accepting comments on the consultation report through July 22, 2026, with a final report expected in October 2026 as a U.S. G20 deliverable. For more information, click here.

On June 10, the Cybersecurity and Infrastructure Security Agency (CISA) issued Binding Operational Directive 26-04 (BOD 26-04), titled “Prioritizing Security Updates Based on Risk,” which supersedes and consolidates two prior directives (BOD 19-02 and BOD 22-01) and establishes a new, risk-based framework for vulnerability remediation across Federal Civilian Executive Branch agencies. Rather than treating all vulnerabilities equally, the new directive prioritizes patching based on four variables: whether the affected asset is publicly exposed, whether the vulnerability appears on CISA’s Known Exploited Vulnerabilities (KEV) catalog, whether the vulnerability is automatable by an adversary, and whether exploitation yields partial or total control of the affected asset, with remediation timelines ranging from three days for the highest-risk combinations to deferral until the next scheduled system upgrade for the lowest-risk scenarios. The directive is implemented in three phases: agencies must immediately update vulnerability management policies, automate KEV reporting through the Continuous Diagnostics and Mitigation (CDM) Dashboard, and continue Cyber Hygiene scanning; within 60 days, agencies must update vulnerability management processes to account for the full CVE database; and within 180 days, agencies must remediate vulnerabilities within the prescribed timelines, continuously tag all publicly exposed assets, and report asset information to CISA every seven days in a machine-readable format. CISA noted that the growing use of AI by threat actors is narrowing the window between patch release and exploitation, making risk-based prioritization increasingly critical to federal network security. For more information, click here.

On June 9, the Congressional Research Service (CRS) published an updated report examining the transition of servicing for defaulted federal student loans from the Department of Education (ED) to the Department of the Treasury, pursuant to an interagency agreement (Treasury-ED IAA) signed on March 19, 2026. As of December 31, 2025, ED’s defaulted federal student loan portfolio comprises approximately $179 billion in loans owed by roughly 7.8 million borrowers (representing about 18% of all federal student loan borrowers) a portfolio that would more than quadruple the number of debtors currently served by Treasury’s Bureau of the Fiscal Service Cross-Servicing Program (CSP), which currently handles approximately 1.9 million debtors and $119.1 billion in federal nontax debt. Under Phase 1 of the IAA, Treasury is to assume responsibility for servicing ED’s defaulted federally held student loans through a graduated referral approach, with ED acknowledging that Treasury intends to revoke the Office of Federal Student Aid’s (FSA) longstanding exemption from the standard Debt Collection Improvement Act requirement to refer delinquent debt to Treasury for centralized collection. Proponents argue Treasury has relevant expertise in managing complex financial systems and collecting delinquent federal debt, while critics contend that Treasury lacks familiarity with the highly unique federal student loan system, a concern supported by a 2016 interim report from a prior pilot program in which Fiscal Service resolved only 4.14% of referred student loans compared to 5.46% for FSA-contracted private collection agencies, with lower performance attributed to slower collections timing, less frequent borrower contact, and the absence of specialized tools and systems tailored to the complexity of student loan rehabilitation and resolution options. For more information, click here.

On June 9, SEC Commissioner Hester M. Peirce delivered remarks at the U.S. Chamber of Commerce Capital Markets Summit, offering a wide-ranging reflection on capital markets regulation as she prepares to leave the SEC after nearly thirty years in Washington, D.C. Peirce celebrated the strength of U.S. capital markets, attributing their success not primarily to government action but to the nation’s foundational commitment to liberty and the organic ability of markets to direct capital to productive ends. She emphasized that the SEC must operate strictly within the boundaries set by Congress and the Constitution and highlighted several recent commission actions she viewed as steps in the right direction, including rescinding climate disclosure rules, revisiting Form PF, and refining the agency’s approach to crypto regulation. She also flagged ongoing concerns, including constitutional questions around the pay-to-play rule for investment advisers, overly aggressive statutory interpretations related to the definition of “dealer,” Rule 15c2-11, and the Foreign Corrupt Practices Act’s internal accounting controls provision, as well as the commission’s expansive use of disgorgement as a remedy — an issue the Supreme Court addressed yet again just days before her remarks, reaffirming key equitable limitations on the remedy while leaving significant questions unresolved. Closing with optimism, Peirce expressed hope that shared interest in healthy, growing capital markets could serve as common ground across political divides, and offered warm words of farewell to her colleagues and the institution she served. For more information, click here.

On June 9, U.S. House Ways and Means Committee Chairman Jason Smith (R-MO) delivered an opening statement at the committee’s first legislative hearing on digital asset taxation in years, arguing that the current tax framework is untenable and that clear rules are essential for the U.S. to remain the global leader in digital assets. Chairman Smith highlighted the rapid growth of cryptocurrency ownership (now held by roughly 67 million Americans across all income levels and industries) and identified three core gaps in the existing tax regime: ambiguity around common transactions like mining and staking, an imbalance between digital and traditional financial assets in terms of tax benefits and anti-abuse protections, and a compliance burden so heavy that using digital assets for everyday purchases is effectively impractical. To address these gaps, the committee examined eight bills and discussion drafts covering a range of issues, including excluding small gains or losses from minor digital asset transactions and stablecoin use, clarifying the tax treatment of mining and staking rewards, extending charitable deduction parity to digital asset donations, applying securities lending and trading safe harbors to digital assets, bringing anti-abuse rules in line with those governing traditional investments, creating a one-time voluntary disclosure program for past filing errors, and closing a territorial residency loophole used to avoid capital gains tax. Chairman Smith emphasized that digital asset tax reform need not be partisan, pointing to bipartisan collaboration among committee members, and urged Congress to act swiftly to provide the clarity and fairness that American investors, businesses, and everyday consumers need. For more information, click here.

On June 4, the Guardian reported that the CFPB deleted at least 2,228 webpages from its website, spanning content published from the agency’s founding in September 2010 through January 30, 2025, including press releases, consumer advisories, congressional testimonies, speeches, and know-your-rights resources for veterans and non-English speakers. The deletions are part of the Trump administration’s broader effort to dismantle the agency. Consumer advocates argue the purge is designed to erase the CFPB’s institutional history and signal a fundamental reorientation of the agency away from consumer protection, noting that the remaining 18 posts published since February 2025 are largely partisan and focused on rolling back prior regulations. The timing is striking given that consumer complaints to the CFPB hit a record 5.4 million in 2025 (double the 2024 figure) and that the agency has returned more than $21 billion to consumers since its inception, leading critics to warn that gutting the bureau has already cost consumers billions and left the financial system less safe. For more information, click here.

On May 22, International Monetary Fund (IMF) Financial Counsellor Tobias Adrian delivered remarks at the Third Conference on Stablecoins and Tokenization, hosted by the Federal Reserve Banks of Boston and New York, offering a sweeping analysis of how tokenization and stablecoins are reshaping the architecture of finance and the policy challenges that follow. On tokenization, Adrian argued that unlike prior waves of digitization, tokenization has the potential to structurally reconfigure how trust, settlement, and risk management are organized through three distinctive features (programmability, shared ledgers, and atomic settlement) shifting risk from institutions to infrastructure and demanding that supervisory frameworks govern code, data feeds, and smart contracts with the same rigor historically applied to regulated institutions. On stablecoins, Adrian introduced a trilemma framework under which issuers cannot simultaneously maintain a par peg, open convertibility, and unconstrained reserve backing, and he analyzed how the three major emerging regulatory frameworks (the EU’s Markets in Crypto-Assets Regulation, the UK’s draft stablecoin regulation, and the U.S. GENIUS Act) diverge significantly on reserve composition, redemption rules, and central bank access in ways that create meaningful regulatory arbitrage risks, particularly for stablecoins issued across multiple jurisdictions. Adrian also addressed the macro-financial risks stablecoins pose to recipient countries (particularly emerging market economies) noting that foreign-currency stablecoins are increasingly functioning as a digital form of dollarization, driven by the same macroeconomic vulnerabilities that historically drove traditional currency substitution, and that the resulting capital flow pressures and erosion of monetary policy transmission fall disproportionately on economies that have no role in designing these instruments or their regulatory frameworks. He closed by calling for stronger macroeconomic fundamentals, robust data reporting mandates, and enhanced international coordination, and noted that the IMF is actively working with international partners under the G20 Data Gaps Initiative to build a more reliable statistical picture of stablecoin activity. For more information, click here.

State Activities:

On July 1, Virginia Code § 19.2-392.16 takes effect, establishing a new Business Screening Services (BSS) program that will significantly change how private background screening companies handle Virginia criminal and traffic history records by imposing registration, licensing, deletion, disclosure, accuracy, and dispute resolution obligations on businesses that collect, assemble, evaluate, or disseminate such records. Under the new law, screening companies must register with the Virginia State Police (VSP) and pay an annual licensing fee of $30,000 to receive electronic notifications of sealing orders, promptly delete any records known to have been sealed, include specified disclosures on each report, including the date the record was collected and a notice that records may have been sealed since that date and implement reasonable procedures to ensure accuracy and investigate disputed records at no cost to the individual. Companies that violate the statute face civil liability of $1,000 or actual damages per violation, whichever is greater, plus costs and attorney’s fees, and willful violations may expose companies to Attorney General enforcement actions of up to $2,500 per violation. Screening companies that are also consumer reporting agencies may satisfy comparable requirements through compliance with the federal Fair Credit Reporting Act and Gramm-Leach-Bliley Act, though state remedies remain available for conduct that violates both state and federal law. For more information, click here.

On June 12, the CFTC filed a federal lawsuit against the state of New Mexico, seeking a declaratory judgment that federal law grants the CFTC exclusive authority to regulate event contracts and a permanent injunction preventing New Mexico from enforcing state gaming laws against CFTC-registered contract markets. The CFTC contends that its exclusive jurisdiction over event contracts and prediction markets under the Commodity Exchange Act preempts any state law purporting to regulate designated contract markets, and CFTC Chairman Michael S. Selig characterized New Mexico’s actions as an attempt to “nullify black letter law and decades of judicial precedent,” with New Mexico joining a growing list of states that have faced similar CFTC litigation, including Arizona, Connecticut, Illinois, New York, Minnesota, Rhode Island, and Wisconsin. For more information, click here.

On June 9, the New York State Department of Financial Services (DFS) issued a pre-proposed regulation to codify and expand its stablecoin oversight in alignment with the federal GENIUS Act. The proposal, new Part 202 of Title 23 of the New York Codes, Rules and Regulations, would replace DFS’s June 2022 stablecoin guidance with a formal rule incorporating the GENIUS Act and the U.S. Department of the Treasury’s proposed “substantial similarity” standards for state regimes. The regulation includes the DFS’ prior requirements for stablecoins backed by the U.S. dollar that are issued under DFS oversight, including for backing and redeemability, permissible reserves, and independent audits, but also addresses new federal provisions, including setting maximum amounts of reserves that can be held at any one custodian and requiring entities to adopt risk management programs addressing internal controls, information security, an internal audit system, asset growth, earnings, insider and affiliate transactions, and service provider arrangements. DFS opened a 10-day pre-proposal comment period, with comments due June 22, 2026, to be followed by a 60-day comment period upon publication in the State Register. For more information, click here.

On June 2, Louisiana Governor Jeff Landry signed Act 751, prohibiting retail businesses from imposing surcharges on customers who pay with a debit card. The law takes effect August 1, 2026. The law defines a surcharge as any additional amount imposed at the time of a transaction that increases the charge to a cardholder for the privilege of using a debit card, and prohibits retail businesses from imposing such charges when a customer chooses to pay by debit card rather than cash, check, credit card, or other similar means of payment. The law establishes a pre-suit notice requirement: a cardholder must provide written notice to the retail business before filing a civil action. If the business cures the violation and reimburses the cardholder within 30 days of receiving that notice, no private right of action arises. Civil suits are limited to willful violations, repeated violations, or violations not timely cured. The Louisiana Attorney General may also bring civil enforcement actions, and courts may award attorney fees, court costs, and investigative costs. Civil penalties of up to $500 per violation may be imposed. For more information, click here.